Are there clear categories of language or techniques that PBS cannot accept as part of an underwriting message?  

Yes.  The FCC (the federal agency charged with enforcing the rules governing noncommercial broadcasters) has highlighted the following as unacceptable:

Price Information

Calls to action

Qualitative or comparative claims

Inducements to buy, sell or lease



Price Information

Any price information, even the word “free,” must be avoided.  So, no straight-out mentions of price (“membership fee of $49.99 a month”), no implied mentions of price (“for less than the cost of a daily cup of coffee”), no sales or price events (“only $25 today,” “grand opening specials,” “ladies’ night”), no general price claims (“lowest prices this side of the Mississippi”),  no incentives based on price or payment options (“we collect no fee until we win your case”), and no interest rates (“7.7% interest rate available now”). ^top

Calls To Action

Phrasing which urges the viewer or listener to interact with the underwriter or its products (“call for more information,” “take a test drive to learn more”), or to take further steps in the direction of a purchase (“ask your doctor about Zithromax”), are not allowed.  At times, language conveying a sense of urgency or intended to create alarm, has also come under FCC scrutiny in this category (“how will your family survive if you have no life insurance?”) when it seems the unstated message is, “You’d better do something about it, soon!” ^top

Qualitative or Comparative Claims

Superlatives and other such rankings must be avoided.  A company may not be described as “one of the largest” or a product as “the most advanced,” even when demonstrably true.  Awards which in essence make qualitative, superlative, or comparative statements, are also unacceptable (“voted #1 in customer satisfaction for the third year in a row,” or “Winner of the JD Powers Award”).  Comparisons to a competitor’s products or services are clearly off limits (“when a Cadillac just isn’t good enough”), and comparisons to previous versions of a product are risky (“new and improved”).  Examples of descriptions the FCC has cited as unacceptable, in context:

  • “We feature new and used cars and excellent service.”
  • “A leading provider of credit and other business services.”
  • “Providing quick long distance telephone connections and clear sound.”
  • “Number one in sales.”


Inducements to Buy, Sell, Rent or Lease

This category seems to be the catch-all for when the others don’t quite fit, so it’s a bit tricky to define.  Here are the examples the FCC provides:  “Six months’ free service,” “a bonus available this week,” “special gift for the first 50 visitors.”  Because the first example already contains the word “free,” you would expect that to be a problem under price information.  The other two examples seem to urge quick action because of “limited-time only” offers. ^top



This may well be a sub-category under “inducement” but hasn’t clearly been singled out by the FCC in any enforcement actions.  However, PBS takes the position that this is a category with its own distinct promotional elements and therefore should be avoided.  For example, an official-sounding endorsement by a group of professionals (“recommended by 4 out of 5 dentists”), or a vignette featuring satisfied customers who describe their good experience with the underwriter’s products or services, would be promotional.  This category would also cover the video technique – which has been the specific subject of enforcement actions – wherein happy, satisfied customers are depicted using the product, usually to a degree seen as excessive within the context of the message.  ^top